Pakistan: Mandatory e-Invoicing for Large Taxpayers
The Federal Board of Revenue (FBR) has issued a new directive, through notification S.R.O. 1413(I)/2025, setting the final deadlines for the mandatory integration of taxpayers into the electronic invoicing system.
The new regulation outlines a clear, phased timeline for different categories of taxpayers to register their systems, complete integration testing with the official platform, and begin issuing electronic invoices on a mandatory basis.
The first implementation date is set for September 1, 2025, and applies to all public companies, importers, and businesses with annual revenue exceeding 1 billion rupees.
Mandatory Electronic Invoicing in Pakistan
July 1, 2025, marks a turning point in Pakistan’s tax system, as mandatory electronic invoicing comes into force for all large taxpayers. This measure, driven by the Federal Board of Revenue (FBR), is part of a broader government initiative to digitize tax processes, strengthen tax oversight, and reduce tax evasion.
The requirement is formalized in the 2024 Finance Bill and official notification F. No. 1(141) ST-L&P/2025/55105-R, submitted to the National Assembly. Both documents confirm that companies classified as large taxpayers are required to fully integrate their accounting, invoicing, and POS systems with the FBR’s electronic infrastructure for real-time transmission of electronic invoices.
Currently, e-Invoicing in Pakistan applies to the sale and purchase of goods, not services. However, in some regions like Islamabad, both goods and services are subject to mandatory e-Invoicing.
Meanwhile, non-corporate taxpayers (such as sole proprietors, simple businesses, or other entities not registered such as legal persons) must register with the FBR by August 1, 2025. While they are not required to implement full system integration by the same date as large taxpayers, registration is a necessary first step for future phases of the e-invoicing program.
Key Dates by Taxpayer Category
July 1, 2025: All registered legal entities must have completed integration with the electronic invoicing system.
August 1, 2025: Non-corporate taxpayers must register with the FBR and complete their integration.
September 1, 2025: Mandatory e-invoicing begins for public companies, importers, and businesses with annual revenue above 1 billion rupees (approx. 3 million EUR).
- Mandatory registration: by August 10, 2025
- System testing: by August 25, 2025
October 1, 2025: Mandatory e-invoicing begins for businesses with annual revenue between 100 million (approx. 300.000 EUR). and 1 billion rupees, and for non-corporate associations or individuals with revenue above 100 million rupees.
- Mandatory registration: by September 10, 2025
- Testing: by September 30, 2025
November 1, 2025: Mandatory e-invoicing begins for businesses with annual revenue below 100 million rupees.
- Mandatory registration: by October 10, 2025
- Testing: by October 30, 2025
December 1, 2025: Mandatory e-invoicing begins for all other taxpayer categories.
- Mandatory registration: by November 10, 2025
- Testing: by November 30, 2025
How Does E-Invoicing Work in Pakistan?
The FBR will implement an electronic invoice validation system.
Integration with the FBR requires companies to adopt technology solutions compatible with the government’s central platform, capable of:
- Issuing e-Invoices that meet all legal requirements. All sales or supplies must be conducted through the e-Invoicing system, generating a real-time verifiable e-Invoice for each taxable supply.
- Reporting invoices in real time or near real time, ensuring proper registration and traceability.
- Electronically storing and archiving invoices in compliance with the technical specifications issued by the FBR, for a period of six years.
As a global provider of electronic compliance solutions, EDICOM offers a comprehensive platform that automates the entire e-invoicing lifecycle in Pakistan: from document generation to real-time validation with the FBR. Our solution integrates with any ERP and ensures full compliance with the technical and legal requirements established by Pakistani authorities.
EDICOM guarantees direct connection with the FBR system through certified channels and complies with local standards for digital signatures, formats, and archiving. Additionally, our experience with implementations in countries with similar models, such as India and Saudi Arabia, allows us to support companies in their digital transition with a guarantee of success, without disrupting their operations.
The Start of E-Invoicing
On November 10, 2023, the Federal Board of Revenue (FBR) of Pakistan announced changes and requirements to the e-Invoicing system, which initially applies only to certain consumer goods. Fast-moving consumer goods are defined as products sold at retail to meet consumers’ daily needs (excluding durable goods).
In December 2023, the FBR published a notification specifying that manufacturers, importers, wholesalers, and distributors of FMCGs must issue sales tax e-invoices through an FBR-approved system. These selected taxpayers were required to start issuing e-invoices from February 1, 2024, via the government’s central platform. The Pakistani government refers to these taxpayers as “integrated suppliers.”
Since April 2024, importers and taxpayers in the FMCG sector have been obligated to comply with the e-Invoicing regime established by the FBR. This measure is part of the government’s broader effort to enhance tax transparency, combat tax evasion, and modernize tax administration.
The requirement means that all commercial transactions conducted by these taxpayers must be reported to the FBR in real time via compatible electronic systems. This includes issuing digital invoices, immediate validation by the FBR, and secure archiving on FBR-approved platforms.
